Application under the DTSV of the Act was rejected on the ground that there is no clarity of legal Heirs and the appeal was filed beyond limitation period. On writ allowing the petition the Court held that time for filing the appeals against the order of CIT(A) had not expired  on the date of filing of declaration. As regards the Legal Heir who desires to   put an end or close to all disputes between the deceased and tax Authorities. The Rejection of application was not valid. The Court also observed that the order of the Court cannot be used by petitioner in any proceedings between petitioner and the legal heirs of Late Kalyani Bhagat too lay claim to any estate of deceased Kalyani Bhagt if there are any such proceedings /disputes pending or may arise in future.

.( AY.1983-84 to 1989-90, 2006-07)